The second sentence of the prospectus makes plain that IMPRESS, the Independent Monitor for the Press, ‘will regulate the press in compliance with Leveson’s criteria’. A later line states that it will be financed by an independent trust which ‘will exist solely to fund a regulator that complies with the terms of the Royal Charter’.

On that basis – that the IMPRESS self-regulator will meet the criteria set out in the Royal Charter – we welcome the initiative, though there are some aspects of the prospectus with which we take issue and which we are eager to raise with IMPRESS.

We have been asked whether this is a Hacked Off project. It is not. Though we have always taken the view that there must be a Leveson-compliant self-regulator and that – given the benefits to news publishers – it was inevitable one would be established, we have not sought to do this job ourselves.

Lord Justice Leveson suggested that it would be ideal if the self-regulator or self-regulators was set up by the industry acting on its own accord, but failing that it is open to any group to set one up, providing some news publishers are involved.

As we know, much of the industry remains in denial about the need for change and is proposing to ignore the judge, Parliament, public opinion and the Royal Charter criteria by simply rebranding and relaunching the PCC as ‘IPSO’. They continue to repeat the lie that this is ‘fully in line with the principles of the Leveson Report’ but IPSO is not ‘Leveson compliant’ and could not, in its present form, be recognised as such under the Royal Charter.

The IMPRESS project appears to offer a valuable alternative for those publishers who appreciate the need for a genuine shift in the culture of self-regulation and who would like to participate in a scheme designed to reinvigorate public trust in journalism.

That said, we have reservations about some aspects of the IMPRESS prospectus.

It states: ‘IMPRESS stands up positively for press freedom’ and ‘IMPRESS would also advocate strongly against the use of any other political mechanism to limit the freedom of the press or individual freedom of expression.’

While no one could challenge a commitment to freedom of expression or doubt the need to defend it actively, there are problems if a self-regulator of the press takes on that advocacy role. Lord Justice Leveson criticised the Press Complaints Commission (PCC) for lobbying for what the industry saw as the interests of freedom of speech while operating a complaints service for the public. Similar criticisms were levelled at the PCC’s predecessor, the Press Council.

The problem is obvious. A self-regulator has to convince the public it will handle complaints impartially and it can’t do that if at the same time it appears to be an advocate for and champion of the industry which is the subject of those complaints.

We will raise this with IMPRESS and will watch with interest how the matter is handled. Our view is that it will be difficult for IMPRESS to meet the Leveson criteria on independence if it is also engaged in advocacy of this kind. This is not to say that freedom of expression should go undefended, but there are many other very able groups who can do that work.

We also note that IMPRESS is coy about the Royal Charter, to the point where it is mentioned by name only once in the 2,000 words of the prospectus. While we recognise that no one, including Hacked Off, ever regarded a Royal Charter as ideal, it is what the industry must now work with and there seems little point in pretending it isn’t there.

Even the Murdoch, Mail and Telegraph newspapers have embraced the idea of a Royal Charter – to the point where they are going to court next month to seek, in the wonderful words of the official summary, ‘permission to appeal the decision to refuse permission to claim for judicial review and permission to rely on fresh evidence’. In plain words, they are fighting desperately for the right to have a Royal Charter of their own.

IMPRESS, we believe, should be more explicit in committing itself publicly to the Royal Charter that is based closely on what Lord Justice Leveson recommended, that has the endorsement of every party in Parliament, that is supported by the victims of press abuses, that has the backing of many of the leading lights in free expression in this country and that is – as the polls demonstrate – what the overwhelming majority of the public wants.

There are other points on which we have concern about the IMPRESS prospectus and we will seek a meeting to discuss them. But that in itself is a welcome and highly important difference between IMPRESS and IPSO – unlike the newspaper proprietors, IMPRESS is not proposing to set up a regulator without public consultation.